Epstein Secrets

ect until you are granted leave to depart by the court or by an officer acting on behalf of the court. This subpoena is issued upon application of the United Stairs of America o. Australian venue, West Palm Beach, FL 33401-6235 DATE August 18.2006 S. Attorney Case No. 0 3-8073 • lc not applicable, enter 'none To be

ubpoenaed. The early voluntary turnover date is prior to September 29, 2006. BY: Sincerely, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY ASSISTANT UNITED STATE ATTORNEY Case No. 08-80736-CV-MARRA P-000182 EFTA00227562 CERTIFICATION OF BUSINESS RECORDS I, the undersigned, , declare that I am: employed

the District Attorney is unable to rebut the presumption that the federal grand jury subpoena is reasonable. (41 Regarding the relevancy question, the United States has set forth in some detail, both in its motion papers and in its in camera submission, the reasons underlying the need for the state grand Jury r

and jury than to protect from delay the progress of the trial after an indictment has been found." Id. at 327, 60 &Ct. at 542; see also Di Bella v. United States, 369 U.S. 121, 124, 82 S.Ct. 654, 656-57. 7 L.Ed.2d 614 (1962) ("This insistence on finality and prohibition of piecemeal review discourage undue

on behalf of the court. (BY) DEPUTY CLERK DATEL September I, 2006 This subpoena it issued upon application umber of Assistant U.S Attorney of the Unitod States of America enuc, lute L 33401-6235 Case No. 08-80736-CV-NIARRA EFTA00227522 • •••••••••• United States District Court SOUTHERN DISTRICT OF FLORIDA TO

.10 15] Witnesses eg=,184(1) 410k184(1) Florida statute imposing secrecy on grand jury proceedings does not create an evidentiary privilege. West's F.S.A. § 905.27; Fed.Rules Evid.Rule 501, 28 U.S.C.A. '555 Lamar Winegeart, 111, Arnold. Stratford & Booth, Jacksonville, Fla., for Greene. Eliz

the District Attorney is unable to rebut the presumption that the federal grand jury subpoena is reasonable. [4] Regarding the relevancy question, the United States has set forth in some detail, both in its motion papers and in its in camera submission, the reasons underlying the need for the state grand jury r

ecial relationships from disclosure. By their very nature they impede the search for the truth and are therefore generally disfavored. Tranunel v. United States, 445 U.S. 40, 50, 100 S.Ct. 906, 912, 63 L.Ed.2d 186 (1980); Herbert v. Lando, 441 U.S. 153, 99 S.Ct. 1635, 60 L.Ed.2d 115 (1979); United States v

.10 [5] Witnesses C=184(I) 410k184(1) Florida statute imposing secrecy on grand jury proceedings does not create an evidentiary privilege. West's F.S.A. § 905.27; Fed.Rules Evid.Rule 501, 28 U.S.C.A. *555 Lamar Winegeart, III, Arnold, Stratford & Booth, Jacksonville, Fla., for Greene. Eliz

privileges in federal court pros. wsings " 1560 shall be governed by the principles of the common law as they may be interpreted by the courts of the United States in the light of reason and experience." The privilege appellants assert, as stated in their motions to intervene, is based solely on state law. [FN

and jury than to protect from delay the progress of the trial after an indictment has been found." Id. at 327, 60 5.Q. at 542; see also Di Bella v. United States. 369 U.S. 121, 124, 82 S.Q. 654, 656-57, 7 L.P.d.2d 614 (1962) ("This insistence on finality and prohibition of piecemeal review discourage undue

nd Jury C=,41.10 193k41.10 [5] Witnesses C=184(1) 410k184(1) Florida statute imposing secrecy on proceedings does not create an privilege. West's F.S.A. § 905.27; Evid.Rule 501, 28 U.S.C.A. *555 Lamar Winegeark III, Arnold. Booth, Jacksonville, Fla., for Greene. grand jury evidentiary Fed

at trial. No more; no less." 2 EFTA00183432 U.S. Department of Justice United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Aye, le Floor Miami, FL 33131 Re: Jeffrey Epstein Dear

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

ated: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN EFTA00183434 Page 2 of 8 Westlaw West's F.S.A. § 951.24 Page 1 C Effective:Pee Text Amendments] West's Florida Statutes Annotated Currentness Title XLVII. Criminal Procedure and Correc

the United States, advised that her January 2001 record was the return from her London, England trip 'The April 2001 CBP record was her return to the United States' ould not recall her travel from advised that her United States March and May 2001 CPB records! Passport was Australia. turned over to the United

d jury than to protect from delay the progress of the trial after an indictment has been found." Id. at 327, 60 S. Cr. at 542; see also Di Bella v. United States. 369 U.S. 121, 124, 82 S.O. 654, 656-57, 7 L.Pd.2d 614 (1962) ("This insistence on finality and prohibition of piecemeal review discourage undue l

k41.10 [5) Witnesses C=.184(1) 410k184(1) Florida statute imposing secrecy on grand jury proceedings does not create an evidentiary privilege. West's F.S.A. § 905.27; Fed.Rules Evid.Rule 501, 28 U.S.C.A. *555 Lamar Winegeart, III, Arnold, Stratford & Booth, Jacksonville, Fla., for Greene. Eliz

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a result of such violation may sue in any appropriate United States District Court and shall recover the actual damages such minor sustains and the cost of the suit, including a reasonable attorney's fee. Any minor a

ovt. Works. httn.//weh7. westlaw r.nm/nrint/nrintctream acrty9cv=Snlit&nrft=1-ITTAT.PRifrs= tnrafirm= Iinannnst EFTA00233448 Page 2 of 8 WShw. West's F.S.A. § 951.24 Page 1 C Effective:fSee Text Amendments) West's Florida Statutes Annotated Currentness Title XLVII. Criminal Procedure and Corre

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

ted: GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ, ATTORNEY FOR JEFFREY EPSTEIN EFTA00223169 Page 2 of 8 Wg41.aw. West's F.S.A. § 951.24 Page 1 C Effective:ISee Text Amendments] West's Florida Statutes Annotated Currentness Title XLVII. Criminal Procedure and Corre

Rule 45(c), Federal Rules of Civil Procedure. 2."Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of cert

10 [5] Witnesses €=•184(1) 410k184(1) Florida statute imposing secrecy on grand jury proceedings does not create an evidentiary privilege. West's F.S.A. § 905.27: Fed.Rules Evid.Rule 501, 28 U.S.C.A. *555 Lamar Winegeart, III, Arnold, Stratford & Booth, Jacksonville, Fla., for Greene. Eliz